ICHRA for Medical and Dental Practices

Medical and dental practices mix owners, clinicians and front-office staff. An ICHRA can give each group its own allowance.

An individual coverage HRA lets a practice set separate allowances for salaried clinicians, hourly support staff and part-time employees, and vary them by office location. The work is in the class design, the treatment of owners and the affordability math.

Ask Whether an ICHRA Fits

Why It Fits

Why practices look at an ICHRA.

Clinical and Support Staff Classes

Salaried and hourly are permitted classes. A practice can offer clinicians one allowance and front-office staff another, as long as everyone in a class is treated the same.

Part-Time Clinicians and Staff

Full-time and part-time are permitted classes, which helps when schedules vary by provider and by day.

Offices in Different Markets

Practices with several offices face different individual premiums. Allowances can vary by rating area, based on where the employee works.

A Known Cost per Employee

A defined allowance gives the practice a predictable cost, even when staffing changes through the year.

A Waiting Period for New Hires

An employer can set a waiting period of up to 90 days, which can match an introductory period for new staff.

A Different Option from Group Health

An ICHRA is not right for every practice. We compare it with the group plan side by side.

What To Watch

The practice issues that decide whether it works.

Owners and Partners

Owners, partners and some shareholders may be treated differently from employees for benefit purposes. Ask counsel and your tax advisor how they fit before designing classes.

Affordability for Larger Employers

Practices with 50 or more full-time equivalent employees must offer an affordable allowance. Test each class.

Smaller Practices Have Options

A practice under 50 employees is not subject to the ACA employer mandate and can also look at a QSEHRA. We compare the options.

Employee Shopping Experience

Staff used to a group plan may need help comparing individual plans. Enrollment support affects take-up.

Notice and Timing

Employees need an ICHRA notice at least 90 days before the plan year, so planning has to start well before the renewal date.

Health Information Rules

Plan data and employee health information are subject to privacy rules. Review how enrollment data is handled with counsel.

What To Ask

What to settle before moving a practice to an ICHRA.

How are owners and partners covered today?

Confirm their status with counsel before drawing class lines.

Which roles belong in which class?

Write the definitions down and test them against the roster.

What does the allowance cost by office?

Model each location, not one average.

Who helps employees buy a plan?

Plan enrollment support before the notice goes out.

Does every class pass affordability?

If you have 50 or more full-time equivalents, test each class.

Is the group plan still the better answer?

Compare the two before you decide.

See the medical and dental practice benefits guide →

Questions We Get

The questions medical and dental practices ask about ICHRAs.

Can a practice offer different allowances to clinicians and staff?

Yes, if they fall into permitted classes such as salaried and hourly, and everyone in a class is treated the same. Counsel should review the definitions.

How are owners and partners treated?

Owners, partners and some shareholders may be treated differently from employees. Ask counsel and your tax advisor before designing classes.

Can the allowance vary by office?

Allowances can vary by rating area within a class, based on where the employee works. The rule should be written and applied consistently.

Does an ICHRA work for a practice with fewer than 50 employees?

It can. The ACA employer mandate does not apply under 50 full-time equivalents, and a QSEHRA may also be an option. We compare them.

Does an ICHRA work for a practice with 50 or more employees?

It can, but the allowance has to meet the ACA affordability test for the year, so model each class. The 2027 affordability percentage is 10.22%.

How early do we need to start?

Employees must receive an ICHRA notice at least 90 days before the plan year starts, and they need time to shop. Plan well ahead.

What notices do we still send?

Employees receive the ICHRA notice, and other compliance notices may still apply. See our employee notices page.

General information about individual coverage HRAs, not legal or tax advice. Plan-specific questions belong with ERISA counsel and your tax advisor, and we will bring them in.

Sources

Where these details come from.

This page summarizes public guidance reviewed in October 2026. Rules change, so confirm current requirements with counsel. Federal agencies now also call ICHRAs CHOICE Arrangements; the rules are unchanged.

CMS: Individual Coverage HRAs →

U.S. Department of Labor: Employee Benefits Security Administration →

Let’s Get to Work

Send us your renewal.

We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.

What to send

The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier

Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.

CFH Insurance Consultants

An independent employee benefits consulting firm. We look at the entire benefits program: cost, plan performance, risk and administration.

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